DIRECTOR OF INCOME TAX Vs. PRIDE FORAMER SAS

JUDGEMENT

(1.) In this appeal, appellants have sought interpretation of Article 12 Sub-Articles (1), (2) & (5) of the Double Taxation Avoidance Treaty between India and France. Those are as follows:

(2.) However, such interest may also be taxed in the Contracting State in which it arises, and according to the laws of that State, but if the recipient is the beneficial owner of the interest, the tax so charged shall not exceed 10 per cent of the gross amount of the interest.